Computation of Profit

Cases

Anthony v. Canada (National Revenue), 2016 FC 955

Approximately eight years after the taxation year in question, the taxpayer made a s. 152(4.2) application to CRA to allow the personal deduction...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Separate Existence taxpayer bound by lease agreements being contracted by his corporation rather than personally 466
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) s. 152(4.2) denials are subject to judicial review 127

Bernick v. Canada, 2004 DTC 6409, 2004 FCA 191

A Bahamian partnership of which the taxpayer was a member purchased bonds at less than 10% of their maturity value, recorded the bonds in its...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence foreign law presumed the same 62
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base cost of bonds equal to their FMV 139
Tax Topics - Income Tax Act - Section 9 - Accounting Principles accounting method must produce an accurate result 179

Bellingham v. The Queen, 96 DTC 6075, [1996] 1 CTC 187 (FCA)

An award of "additional interest" received by taxpayer pursuant to s. 66(4) of the Expropriation Act (Alberta) (a provision which required...

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Kaneff Properties Ltd. v. The Queen, 95 DTC 5345, [1995] 2 CTC 177 (FCTD)

At the time the taxpayer (a real estate developer) acquired land in 1970, it had an alternative intention of possibly reselling the land at a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate residential land developer had change of use of parcel from income to capital account after 6 years 131

Whittles v. Uniholdings Ltd. (No. 3), [1995] BTC 119 (Ch. D.)

In order to lower the effective interest rate payable by it on a loan of £14,056,000, the taxpayer and its bank agreed that at the time the bank...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Nature of Income 210

Pollock v. The Queen, 94 DTC 6050 (FCA)

Hugessen J.A. indicated that it had not been shown that the Minister was wrong in computing the taxpayer's gain on income account from the...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus demolition of assumptions by taxpayer leaves Minister with the ordinary civil-suit persuasive burden 107

The Queen v. Cyprus Anvil Mining Corp., 90 DTC 6063 (FCA)

Urie J.A. found that the taxpayer effectively was precluded from computing its income for purposes of the former 36-month new mine holiday (by...

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Magilb Development Corp. Ltd. v. The Queen, 87 DTC 5012, [1987] 1 CTC 66 (FCTD)

A director and controlling shareholder of the taxpayer made "[t]entative overtures" (p. 5014) to the City of Red Deer in 1971 respecting the...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 39
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate tentative overtures for subdivision did not effect a change in use 107

Hughes v. The Queen, 84 DTC 6110, [1984] CTC 101 (FCTD)

The taxpayer purchased an 18-suite apartment building in Vancouver in January 1973, mostly with the proceeds of mortgage financing at high rates...

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Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC)

The taxpayer acquired a mortgage at a discount, and later foreclosed on the mortgage and sold the foreclosed property for a purchase price which...

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Silverman v. MNR, 60 DTC 1212, [1960] CTC 262 (Ex Ct)

The assumption by the purchasers of an inventory property of a mortgage (including a mortgage bonus) constituted part of the proceeds of...

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Tuxedo Holding Co. Ltd. v. MNR, 59 DTC 1102, [1959] CTC 172 (Ex Ct)

The original shareholders of the taxpayer had transferred raw land (which they had valued at $355,000, based on an estimated selling price for...

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Royal Trust Co. v. MNR, 57 DTC 1055, [1957] CTC 28 (Ex. Ct.)

Admission fees and annual membership dues of various officers of the taxpayer at social clubs which were paid by the taxpayer in order to help...

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See Also

Polonovski v. Agence du revenu du Québec, 2020 QCCQ 8943

Two individuals acquired a rental property, consisting of a duplex and triplex, in 2004. In 2009, they decided to enlarge the duplex and convert...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate partition of property was consistent with its sale generating business profits 679

GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at 908], 2015 TCC 146

Leases by the taxpayer ("GMAC") to GM dealership customers leases stipulated a "residual value" at which the customer could purchase the vehicle...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) amount subject to potential repayment obligation was not received 258
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.4) amounts replaced reduced lease income rather than contributing to leased vehicles' cost 239
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing capital tax accrued from day to day 226
Tax Topics - Income Tax Act - Section 9 - Compensation Payments payments received in consideration for reducing lease payments were compensation for lost lease income, and s. 9 income 284
Tax Topics - Income Tax Act - Section 9 - Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified 221

Chronis v. The Queen, 2010 DTC 1188 [at 3441], 2010 TCC 218

Losses sustained by the taxpayer, when most of the property used by him in a business of selling pirated satellite television signals was seized...

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Beaudry v. The Queen, 2010 DTC 1266 [at 3853], 2008 TCC 17, aff'd Romar v. The Queen, 2010 DTC 5076 [at 6816], 2009 FCA 48

The taxpayers set up an avoidance scheme wherein they bought partnership units with promissory notes to pay 7-10 years later an amount in...

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Saskferco Products Inc. v. The Queen, 2007 DTC 1183, 2007 TCC 462, aff'd 2008 FCA 297

Sales revenue that the taxpayer earned in the United States were required to be translated into Canadian dollars at the current rate of exchange...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange loan repayments on capital account 164

Hollinger Inc. v. The Queen, 98 DTC 1913 (TCC), aff'd 99 DTC 5500 (FCA)

In finding that shares with a high adjusted cost base but nominal fair market value that the taxpayer had acquired with a view to realizing the...

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Bondar v. The Queen, 97 DTC 517 (TCC)

In connection with the acquisition of the shares of a corporation ("LTM") by another corporation ("HSS") of which the taxpayer was the general...

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Federal Commissioner of Taxation v. Energy Resources of Australia Ltd., 94 ATC 4923, [1994] FCA 924 (Full Fed. Ct.)

Hill J. stated, in obiter dicta (at p. 4950-4951):

"In my view, where a discounting transaction is conducted wholly in a foreign currency, the...

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Roos v. The Queen, 94 DTC 1094, [1994] 1 CTC 2105 (TCC)

Land which the taxpayers acquired as capital property for use as a tree nursery was converted into inventory when they made formal applications to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) conversion when application for plan of subdivision 223

Marina Québec Inc. v. MNR, 92 DTC 1392 (TCC)

Tremblay J. applied the decision in Osborne v. Steel Barrel Co. Ltd. (1942), 24 TC 392 in finding that inventory which the taxpayer acquired in...

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Richard Street v. Minister of National Revenue, 91 DTC 369, [1991] 1 CTC 2240 (TCC)

The cost to the taxpayer of shares which he disposed of on income account following the exercise of employee stock options included the amount of...

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Jones v. MNR, 90 DTC 1849, [1990] 2 CTC 2406 (TCC)

The taxpayer, a building contractor, acquired 4,990 acres of raw unserviced land for his personal use in 1967. The taxpayer’s neighbour, with...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) conversion when retained engineers 156

Mackinnon v MNR, 88 DTC 1651 (TCC)

The taxpayer filed a proposed plan of subdivision respecting a four-acre piece of land near Charlottetown with the Planning Division of the...

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Cantor v. MNR, 85 DTC 79, [1985] 1 CTC 2059 (TCC)

Twenty eight townhouses which the taxpayers purchased as rental properties in 1969 were not converted into inventory when a number of years later...

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Dawd v. MNR, 81 DTC 888, [1981] CTC 2999 (TRB)

The taxpayer acquired land with a barn outside Thunder Bay for the purpose of constructing a replacement home there, but then learned that there...

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Gold Coast Selection Trust, Ltd. v. Humphrey (1948), 30 TC 235 (HL)

The taxpayer transferred mining concessions to a newly-incorporated company in consideration for shares of the company contemporaneously with an...

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Osborne v. Steel Barrel Co., Ltd. (1942), 24 TC 293 (C.A.)

A corporation purchased various assets including inventory in consideration for the payment of £10,500 and the issue of 29,997 fully-paid shares...

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Administrative Policy

5 November 2003 Internal T.I. 2003-0043277 F - Benefit-Use of Automobiles

Automobiles in the inventory of a car dealer (Opco) were made available to individuals related to the CEO (X), who was also an indirect...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) - Paragraph 246(1)(a) s. 246(1)(a) application re mother’s use of a car of Opco controlled by her son’s Holdco to her rather than son turned on whether her minority Holdco had significant influence over Opco 288
Tax Topics - Income Tax Act - Section 15 - Subsection 15(5) application of s. 15(5) to shareholder’s use of company automobile 72
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) automobiles in car dealer inventory used for employee’s personal use remained in inventory, cf. if converted primarily to personal use of shareholder (which would not be a disposition) 314

17 January 2020 External T.I. 2017-0685341E5 - Tax Comparison of the FIT & Net Metering Programs

Under the Net Metering Program administered by the Ontario Power Authority, a participant who generates electricity primarily for its own use from...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit credits received under the Ontario Net Metering Program respecting electricity generated for personal consumption are not income 210
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 general Class 43.1 or 43.2 treatment of specified energy property rules to equipment used in the Ontario Feed-in Tariff program 157
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(25) application of exception to the specified energy property rules to equipment used in the Ontario Feed-in Tariff program 364

22 January 2020 External T.I. 2014-0559281E5 F - T5008

CRA indicated that in a short sale, the cost of the shares sold short is the fair market value of the shares at the time they are borrowed for the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) writing of call option (with deemed nil ACB) is reported as having nil “cost” on T5008 99
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) option writer can deduct its expenses from deemed s. 49(1) proceeds 125
Tax Topics - Income Tax Regulations - Regulation 230 - Subsection 230(2) “cost” of call options closed out by writer is nil, not the cost of offsetting call option purchase/cost re short sale is the FMV of the borrowed shares 351

6 January 2020 External T.I. 2019-0800941E5 - In-kind contributions to a NPO

A non-profit organization (the “NPO”) has been soliciting in-kind contributions of goods and services from local suppliers (the...

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8 August 2019 Internal T.I. 2018-0776661I7 - Bitcoin Mining

Respecting the treatment of a taxpayer who is in the business of Bitcoin “mining,” the Directorate stated:

Generally, when a miner...

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7 February 2018 External T.I. 2016-0673331E5 - Stock Options - CCPCs

A consulting company (“Serviceco”) received stock options (the “Options”) on the shares of the parent (“Parentco”) of its arm’s...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Options FMV of a stock option is higher than its in-the-money value 94

9 May 2016 Internal T.I. 2016-0638461I7 - Vehicle provided to subcontractor

A corporation provides an automobile to the shareholder of corporation that carries on a “personal services business” (“PSB”). The...

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25 September 2015 External T.I. 2015-0596921E5 - Conversion from inventory to capital

Do the rules in s. 45(1) apply where a home builder, who initially held a property as inventory, commenced to use it for his personal use, having...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) no 45(1) on conversion of house inventory to personal use 130

23 December 2013 Internal T.I. 2013-0514701I7 - Bitcoins

When asked to address the consequences of buying and selling goods in exchange for Bitcoins, CRA noted that a sale of property or services for...

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Example

…Ms. B buys a book from the bookstore using Bitcoins. The value of the book is $20. Mr. A [the vendor] would treat the transaction as if he had...

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5 November 2013 CRA Press Release "What you should know about digital currency"

Where digital currency is used to pay for goods or services, the rules for barter transactions apply. …For example, paying for movies with...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives capital/income treatment of Bitcoin sales informed by securities trading principles 62

1 November 2013 External T.I. 2013-0501131E5 - Micro-FIT Rental Income

The taxpayer, who co-owned a house equally with his or her spouse, contracted with a solar equipment provider to have solar panels installed on...

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5 April 2013 External T.I. 2012-0471151E5 F - Binding Agreement

Opco, which acquires an immovable, shortly thereafter agrees with an unrelated individual to pay 40% of the annual net rental income to the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense counter letter payments non-deductible because Quebec counter letter entered into after apparent letter 239

22 October 2012 External T.I. 2012-0455921E5 - Free Rent in Lieu of Receiving Interest Income

The vendor of two residences takes back a second mortgage on the property from the purchaser, does not charge interest on the second mortgage and...

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28 March 2012 External T.I. 2011-0430411E5 - Conversion of capital property to inventory

When a taxpayer holding an apartment building as capital property decides to convert it to condominiums and sell them, the property is converted...

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22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities

the correspondent noted that under the GAAP that prevailed in 2008 (contained in Section 3855 of the CICA Handbook) taxpayers whose financial...

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27 October 2011 Internal T.I. 2010-0382161I7 F - CPN-144 - remises et ristournes

In light of their treatment under International Accounting Standard (IAS) 2, "Inventories," and Emerging Issues Committee (EIC) Abstract EIC-144,...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) change in methodology for determining cost does not require CRA approval 65

8 September 2009 External T.I. 2008-0299771E5 F - Gain on Disposition of Debt

Over the years, A made advances (the "Debt") to Aco which it wholly owned, and then sold all the shares of A to an arm’s length purchaser, as...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) partial repayment of low-ACB debt generates a capital gain 97

2 July 2009 External T.I. 2009-0319211E5 F - T5008 : Contrat d'opération à terme (Futures)

A client of a brokerage goes long a futures contract on a particular Government of Canada bond series and subsequently closes out the position by...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 230 - Subsection 230(2) amount to be entered on T5008 as "proceeds of disposition or payments" is net gain or loss on closing out futures contract 225

2 January 2008 External T.I. 2007-0228241E5 F - Programme canadien d'options familles agricoles

Regarding payments made under the Canadian Farm Families Options Program (Options Program) to provide farmers and their families with immediate...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(r) - Subparagraph 56(1)(r)(iv) payments under the Canadian Farm Families Options Program to those without a farming source of income would be included under s. 56(1)(r)(iv) 97
Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Earned Income payments under the Canadian Farm Families Options Program to those without a farming source of income would be excluded from earned income 130

8 October 2004 APFF Roundtable Q. 36, 2004-0087041C6 F - Option d'achat d'actions conférée à un consultant

CRA indicated that when a consultant receives a stock purchase option as payment for services rendered, the fair market value of the option on the...

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13 December 2004 External T.I. 2004-0088971E5 F - Change étranger

In the course of a general discussion of transactions of a portfolio company with a USD and Canadian dollar bank accounts and that was assumed to...

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8 November 2004 Internal T.I. 2004-0076271I7 F - Émission d'options d'achat d'actions

CRA noted that it was subject to debate whether the FMV of stock options issued by a corporation as consideration for the purchase of assets or as...

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8 June 2004 Internal T.I. 2004-0067401I7 F - Dépenses d'une entreprise illégale

The taxpayer, had been charged for carrying on an illegal activity, and had not kept books and records. The TSO performed a net worth assessment....

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus onus on taxpayer, who did not keep records, to displace the net worth assessment results, with documentation or other “acceptable evidence” 130
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16) terminal loss when illegal equipment was forfeited to the Crown by court order 122
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Disposition of Property disposition when illegal equipment was forfeited to the Crown by court order, rather than when it was seized by the RCMP 167
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal fees incurred to defend criminal charges for carrying on an illegal drug business were non-deductible 138

16 April 2003 Internal T.I. 2002-0160807 - Foreign exchange - Hedged receivables

Where foreign currency denominated accounts receivable are hedged by foreign currency forward contracts, the foreign currency denominated accounts...

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15 July 2002 Internal T.I. 2002-0151247 - Stock Options Issued to Non-Employees

As there would be no market for an incentive option issued to a consultant by a Canadian corporation, and the exercise price at the time of grant...

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19 September 2001 External T.I. 2001-0092085 - Transfer of Obligation under Short Position

The assumption of a short sale obligation of an individual by a corporation controlled by him would result in realization of the accrued gain or...

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11 September 2001 External T.I. 2001-0087365 - SHORT SALES

A transfer of securities by a lender to a borrower under a short sell arrangement to which s. 260 does not apply generally results in a...

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7 March 2001 External T.I. 2001-0068965 - CAPITAL PROPERTY V. INVENTORY

"It is unlikely that the mere act of stratifying an apartment building will result in such a conversion [from capital property to inventory]."

2 March 2001 External T.I. 2001-0066515 - Interest-Free Loan - Bartering

Tenants of a seniors residence building owned and operated by a charitable organization and who receive a reduction in their rent if they make an...

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20 July 2000 Internal T.I. 2000-0035017 - Conversion Capital Property to Inventory

When trucks of a leasing company reach the termination of the respective leases at the three-year point, there is a conversion of capital property...

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3 May 2000 External T.I. 1999-0013915 - STOCK OPTIONS TO INDEPENDENT CONTRACTORS

Where options are granted to an independent contractor as a result of the supplier/customer relationship, it will be required to include in...

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11 April 2000 Internal T.I. 2000-0001327 - INDEX LINKED GIC CONTINGENT LIABILITY

The CCRA will accept the use of either the mark-to-market method or the realization method by mutual funds in accounting for derivatives provided...

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16 November 1999 External T.I. 9902145 - STOCK OPTIONS

Where corporation B pays in part for services rendered by corporation A by way of the issuance of stock options, the fair market value of the...

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14 August 1996 External T.I. 9614785 - BARTER TRANSACTION

With respect to an agreement entered into between a trader holding a substantial block of shares of a company in inventory, and a promoter who...

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24 April 1995 External T.I. 9427715 - SECURITIES LENDING

Where a borrower of shares returns the shares to a lender with which it does not deal at arm's length, it will dispose of the shares for proceeds...

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18 May 1994 External T.I. 9329915 - WHETHER 53 APPLIES TO INVENTORY

In response to a query as to whether the rules in s. 53 applied in computing the income or loss on the disposition of a limited partnership...

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30 March 1994 External T.I. 9337225 - SHARES HELD AS INVENTORY

On the redemption of shares held as inventory, a deemed dividend will arise pursuant to s. 84(3) and, to the extent that the paid-up capital of...

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4 March 1994 Internal T.I. 9321217 - SALE OF BURIAL PLOTS

The sale of burial plots by cemetery operators is characterized by RC as similar to the granting of an easement, with the result that there is a...

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21 February 1994 External T.I. 9335765 F - Conversion From Inventory to Capital

Where a taxpayer permanently converts real estate from inventory to personal-use capital property, the ultimate sale of the real estate will not...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) no s. 45 application to conversion of inventory to personal use 50

1994 A.P.F.F. Round Table, Q. 47, 5M08340

When a taxpayer acquires shares of a corporation in financial difficulty, as a speculation, for an amount ($100,000) that is less than the...

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1 February 1993 T.I. (Tax Window, No. 28, p. 11, ¶2386)

Where the cost of developing a golf course situate in the middle of a residential development exceeds its estimated fair market value, the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) 59

24 December 1992 Memorandum (Tax Window, No. 27, p. 14, ¶2337)

Unrealized gains and losses on gold loans of a gold producer that are designated by it as an effective hedge of its gold production should be...

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25 September 1992 T.I. (Tax Window, No. 23, p. 11, ¶2171)

Changes in the shareholders of a corporation (including an acquisition of control) will not by themselves justify a change in the accounting...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Accounting Principles 29

8 January 1992 T.I. (Tax Window, No. 27, p. 19, ¶2359)

Where a corporation transfers land as capital property on a rollover basis to a subsidiary which acquires the land to develop for resale, the...

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92 C.M.T.C - Q.5

RC's position that a mining company must mark a gold loan to market applies even where the company only entered into one gold loan.

30 November 1991 Round Table (4M0462), Q. 13.1 - Conversion of Capital Property into Inventory Property (C.T.O. September 1994)

Where real property that is used for the purpose of gaining or producing income from a business or property is converted from capital property...

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4 September 1991 T.I. (Tax Window, No. 9, p. 20, ¶1445)

Where there is a partial repayment of a debt acquired on income account at a discount, the taxpayer may use either the part disposition method or...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 53

90 C.P.T.J. - Q.11

Discussion of the consequences of a principal business corporation borrowing a million barrels of crude oil to be repaid through production from a...

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22 May 1990 T.I. (October 1990 Access Letter, ¶1451)

Discussion of computation of income from a joint venture.

IT-490 "Barter Transactions"

Meaning of barter

3. A barter transaction is effected when any two persons agree to a reciprocal exchange of goods or services and carry out that...

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Words and Phrases
barter

IT-102R2 "Conversion of property, other than real property, from or to inventory" 22 July 1985

8. Where capital property is converted to inventory, the action of conversion does not constitute a disposition within the meaning of paragraphs...

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IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa" 16 September 1986

10....where real estate is converted from capital property to inventory...for real estate that is used for the purpose of gaining or producing...

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Articles

Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report

Typical structure of a trade receivables securitization (pp. 12:21)

[In] [t]he typical structure of a trade receivable securitization…the seller...

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Dent, "Going for the Gold", CA Magazine, January 1990, p. 23

Includes a discussion of the tax treatment of forward gold sales.

Harris, "Tax Aspects of Condominium Conversions and Lease Inducement Payments to Recipients", 1986 Conference Report, c.45.

Tetreault, "Canadian Tax Aspects of Asset Securitization", 1992 Conference Report, c.23

Discussion of whether the transfer of purchased receivables from the seller to a special purpose vehicle under a trade receivables securitization...

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Hudec, Jenkins, "Recent Financial Innnovation in the Canadian Energy Sector", 1991 Canadian Petroleum Tax Journal, Spring 1991, p. 85

Discussion whether a receivables securitization program gives rise to a "sale".

Fryers, "'Net Serve! One to Come!' (The Net Profits Interest in the Oil and Gas Industry - An In-Depth Analysis)", 1988 Canadian Petroleum Tax Journal, Spring 1988, p. 121

Discussion of the extent to which royalties or other payments computed by reference to profit are deductible.